Planning and training are essential elements in effective spill response. You shouldn’t consider one aspect without the other though, especially when it comes to potential hazardous waste spills.

Planning Ahead for Safety

Under the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard, the Occupational Safety and Health Administration (OSHA) requires facilities that produce and store hazardous waste to have a written plan that documents emergency spill response operations [29 CFR 1910.120(b)].

When writing an emergency response plan, identify spill-prone areas in your facility and customize a plan of action for each based on the volume or nature of the chemicals stored. Response to a 1 oz. laboratory spill will be much different from response to a break in the main feed line of flammable material.

Documenting possible scenarios and detailing the steps for effective response is crucial to thorough planning. Locate available resources and purchase needed items for each of these scenarios.

Plans should also detail employee responsibilities. Outline duties by job title rather than employee names to help managers facilitate training based on an employee’s job description and reduce the number of times the plan needs to be altered due to personnel changes.

Levels of Training

With plans in place, coordinators can then determine the levels of training needed. Keep in mind that it may not be practical or necessary to train everyone at the facility, but rather only those who will have a role in responding.

Before outlining employee responsibilities and administering training, it’s worth considering if the spill response should be outsourced. The HAZWOPER standard does allow the option for employees to evacuate the facility in the event of a spill if the company pre-arranges to have a fully-trained outside emergency team respond to the spill.

If your company will work with outside resources to respond to spills, it must be well-documented in your spill response plan and include contact information. The plan should also include a letter or other documentation from the outside resource(s) stating their commitment and detailing their services.

When employees will handle emergency releases, OSHA requires the following levels of training, depending on the extent to which workers will be involved in response:

First responder awareness level: This level is “baseline” training, appropriate for anyone likely to encounter a hazardous materials spill at your facility. These employees need to know the dangers of chemicals stored at the facility, as well as whom to contact to initiate the proper response. [29 CFR 1910.120 (q)(6)(i)]

First responder operations level: In addition to recognizing a spill and notifying others, employees trained to operations level can initiate basic spill control, containment or confinement measures, but will not actually be involved with stopping the flow of a release or with spill cleanup measures. These employees can also implement decontamination procedures. [29 CFR 1910.120 (q)(6)(ii)]

Hazardous materials technicians: These responders have the skills of both awareness- and operations-level employees. They are also trained to stop the flow of a spill and clean up any discharge. These employees receive a more in-depth training on chemical safety, selection of personal protective equipment and how to function within the incident command system. [29 CFR1910.120 (q)(6)(iii)]

Hazardous materials specialists: These responders have specialized knowledge on certain hazardous materials. They support response technicians and act as a liaison with governing agencies. Knowledge of local and state emergency response plans is also an essential part of their training. [29 CFR 1910.120 (q)(6)(iv)]

On-scene incident commanders: These responders are trained to “assume control of the incident scene.” They must be able to implement the emergency response plan and know the risks involved with the chemicals spilled. Training also includes knowledge of state and regional response plans and teams. [29 CFR 1910.120 (q)(6)(v)]

Thorough spill response plans help everyone know what is expected in an emergency, and training helps ensure that plans will run smoothly when and if they are ever needed.

Karen

Karen D. Hamel, CSP, WACH, is a regulatory compliance professional, trainer and technical writer for New Pig. She has more than 22 years of experience helping EHS professionals find solutions to meet EPA, OSHA and DOT regulations and has had more than 100 articles published on a variety of EHS topics. Karen is a Certified Safety Professional (CSP), Walkway Auditor Certificate Holder (WACH), Community Emergency Response Team (CERT) trainer and hazmat technician. She also serves on the Blair County, Pa., LEPC and has completed a variety of environmental, safety, emergency response, DOT and NIMS courses, including Planning Section Chief. She has conducted seminars at national conferences and webinars for ASSE and other national organizations. She can be reached at 1-800-HOT-HOGS (468-4647) or by email karenea@newpig.com.

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